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A Colombian company asks whether the Spain-Colombia treaty to avoid double taxation applies to a loan obtained from a Spanish bank branch in the US. The DGT confirms that it does, as the branch lacks independent legal personality and the bank is a Spanish tax resident.
Cuestión planteada ¿Resulta aplicable a las relaciones entre la consultante y la sucursal bancaria el Convenio para evitar la doble imposición hispano colombiano?
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